Victory

OBJECT TO THE: "Installation of mobile base station to include erection of 20m monopole with a headframe of six antennas and one 600mm dish at Pumping Station, Batchworth Depot, Harefield Road, Rickmansworth. Reference number: 15/0158/FUL"

This petition made change with 129 supporters!


OBJECTION TO THE PLANNING APPLICATION:

  • Size of the base station: The Design and Access Statement states that “the installation willnot be visually dominant within the streetscene”. The statement also says that the mast willbe “shielded somewhat by the surrounding trees and vegetation”. Given that thesurrounding trees are, at most, 12m high (as noted per the Supplementary Information document), there will be totally inadequate shielding of this eyesore. In addition, most of the surrounding trees are deciduous, so in autumn and winter, the trees will provide no shielding whatsoever. The Supplementary Information document also tries to argue that “the streetscape itself also houses a number of vertical installations in the form of lightposts and telegraph poles”. These objects are merely a few metres high and are incomparable to a 20m installation. 

The base station, at 20m, will tower above all surrounding buildings and trees. The base station is totally disproportionate to its surroundings and will create a huge eyesore in the community, which will be visible from a long distance away. 

  • Appearance of the base station: The design and access statement states that “the headframe design is a permeable structure”, and that this type of antenna will “blend inwith the skyline better”. This is nonsense, since the antenna is totally out of keeping with all surrounding buildings, and is located right by the river Colne, canal and Aquadrome. It cannot possibly be deemed to “blend in” with these beautiful natural surroundings. The installation will be visible from both the canal and Aquadrome.

The design and access statement also notes that “some tree cover surrounds this location, and will provide partial screening and a backdrop for the installation”. As noted above, some of these trees are at best 12m high, and largely deciduous, so will provide totally insufficient screening. 

The Supplementary Information document states that “the height of the installation has been established as the minimum practicable height that will achieve the desired coverage levels when considering the heavy tree clutter around the site and the [sic] in the wider area.” Thus the proposal documents are on the one hand saying that there is some tree coverage to partially shield the base station, but then on the other hand admitting that the base station would need to be significantly higher than the surrounding trees, and thus could not possibly be sufficiently shielded from sight. 

The Supplementary Information documents states that “the mast will be galvanised, and the cabinets will be painted Fir Green”. A 20m galvanised mast will be totally out of keeping with the surrounding area. 

The Supplementary Information document states that the choice of design will ensure “the proposal will not look incompatible in the area, as it has been designed to blend in with the surrounding infrastructure on the site”. Whilst the proposed location is a depot, the base station is significantly higher than any of the depot’s buildings, and is surrounded by residential and nature areas. The installation will definitely not “blend in” with its surroundings. 

The document also states that the installation “will not strongly impact residential or visual amenity and or create any undue impacts in the locality”. This is categorically untrue. Many residents are opposed to this installation and it will have a significant negative impact on the visual amenity of the locality.  

  • Inappropriate location: The design and access statement notes that “the site is locatedwithin a utilities compound, away from the main street frontages and any residential uses.”However, the entire surrounding area is residential, in very close proximity to the basestation. There is a large residential community, in both houses and canal boats, living in veryclose proximity to this proposed site.

The statement also says that the proposal “will not detract from the natural characteristics of the locality”. The proposal will in-fact significantly detract from the appearance of the natural habitat in immediate proximity to the utilities compound, namely the River Colne and the canal, and the nearby Aquadrome. 

The Supplementary Information document discusses the proposed location. It makes reference to the Three Rivers Waste Services Depot to the east and west, to the Tesco superstore to the west, and Trinity Court offices to the rear. It also references a cluster of houses to the east, but states that “it is not considered that significant detrimental impacts will be created by the installation, especially given its proposed siting”. The documents appears to totally ignore the huge residential area to the south, namely Harefield Road, Landford Close, Sherfield Avenue, Plaitford Close and surrounding roads. The installation will be visible to almost the whole of this area, having a hugely detrimental impact on the appearance of the neighbourhood. 

  • Insufficient evidence of the demand for service: “Telefonica has identified the need toimprove existing 2G and 3G coverage in the area whilst introducing a new level of service for 4G technologies." The planning documents make no attempt to demonstrate why there is there is a compelling need to introduce 4G technologies in the area.

“Mobiles can only work with a network of base stations in place where people want to use their mobile phones or other wireless devices. Without base stations, mobile phones and other devices we rely on simply won’t work” This does not provide any evidence for justifying the proposed location of the base station. 

The Supplementary Information document shows a map of current 3G coverage in the locality. The document states that “the coverage is below par in this area in comparison to the rest of Rickmansworth, and can be improved upon.”

The Supplementary Information document states that “the site has been designed so that it can also accommodate a site share with Vodafone Limited in the future if they need coverage improvements across the area”. 

According to O2’s website page detailing mobile phone coverage, the South of Rickmansworth is deemed to have good coverage indoors and outdoors for 2G, 3G and 4G.

According to Vodafone’s website page detailing mobile phone coverage, the South of Rickmansworth is deemed to have good coverage indoors and outdoors for 2G, 3G and 4G. 

Therefore the suggestion in the planning documents that additional coverage is needed in South Rickmansworth is not substantiated by either O2 or Vodafone’s publicly available information on company websites. Thus coverage should not be used as an argument for planning at this site. 

  • Flood risk: The Application form states that the site is not within an area at risk of flooding. However, the Environment Agency website shows that almost the whole surrounding area is at risk of flooding. I therefore do not believe it is possible to conclude definitively that this area is free of a flood risk.

  • Heritage site: The Supplementary Information document states that: “Policy DM14 appliesto telecommunications proposals within the district as follows: (aii) Preserve or enhance thespecial character of all heritage assets.” There are two houses on Harefield Road, directlyopposite the proposed installation site, that are Grade II Listed. These are number 21 and 25, Harefield Road. (English Heritage Building ID 158804). Placing a huge installationopposite these heritage assets would therefore seem to be contrary to Three Rivers Planning Strategy.

  • Historical and natural area: This part of Rickmansworth contains both Batchworth lock, an historical part of the town, and the beautiful natural areas of the canal, River Colne, and thenearby Aquadrome. The installation would be totally out of place in these surroundings and would be a permanent blot on the landscape.

  • Visual amenity of nearby properties: This installation would be visible both from the house, and garden, of Harefield Road, Landford Close, Sherfield Avenue, Plaitford Close and surrounding roads. It would ruin the enjoyment of what is a lovely, private residential location. The installation would be visible from both the front and back windows of the surrounding houses, overlooking gardens, completely blighting the outlook.

  • Potential health concerns: The CTIL document states that “the proposed equipment andinstallation is designed to be in full compliance with the requirements of the radio frequency(RF) public exposure guidelines of the International Commission on Non-Ionising Radiation(ICNIRP)”. Whilst it is not possible currently to conclude that base stations located inresidential areas can harm health, there is insufficient scientific evidence to conclude thatthere is no health risk. There is also a large amount of anecdotal evidence that suggests thatthere are health effects on people living near to base stations, and some European countriesare recommending that base stations are located away from residential areas. The proposedsite of the base station is in a residential area full of families with children, very close to StMary’s Primary School, and Batchworth Sea Scouts. It is a wholly unsuitable site, given that it cannot be concluded with 100% certainty that there will be no adverse health effects on thelocal community.

The Supplementary Information document states that “the balance of evidence did not suggest that exposures to radio frequency fields below international guidelines could causeadverse health effects, although it is acknowledged that biological effects might occur below these values."

One of the conclusions of the Stewart report was that “Some people’s well-being may be adversely affected by the environmental impact of mobile phone base stations sited near their homes, schools or other buildings, as well as by their fear of perceived direct effects.”

Arguing that no evidence has been found to date of adverse health issues is not the same as saying there is no potential impact. There is sufficient uncertainty in the scientific literature to date to cast doubt on the safety of these installations, particularly when located close to residential, and school, areas. 

  • Inconclusive evidence of accordance with planning policy: The Supplementary Information document concludes that “Considering the above points, the proposal complies with thepolicy outcomes of the Three Rivers District as follows:

  • “The proposal will not adversely affect the external appearance of the pumping station. The top portion of the mast (mostly antenna) will be visible from the streetscape, but it will not be seen as out of place given the utilities use at the site. In any case, the Landlord has given consent to housing the installation;” At least 8m of the mast will be visible above the trees, and in winter far more of the mast will be visible. This will not just be the antenna. The mastis totally out of keeping with the other uses of the site. The only other objects that arecurrently visible at the site are low rise buildings and vehicles. The fact that the landlordmay have given consent to house the installation has absolutely no bearing on the external appearance of the mast.

  • “No heritage assets are located in the vicinity of the site”. In fact, 21 and 25, Harefield Road,both Grade II listed, are directly opposite the site. In addition, an important historical area of Rickmansworth, Batchworth Lock, and the River Colne, the Canal and the Aquadrome are all located by the site.

  • “As per section 6, all potential site options were thoroughly considered. No masts exist in the area for sharing, however it should be noted that the proposal to house two operators and thus potentially reduce the number of necessary installations in the area;” Stating that other potential sites were considered does not automatically mean that this site is suitable. In addition, I question the argument of demand, given the information on O2 and Vodafone’s websites regarding network coverage. Stating that the mast could be shared is not an appropriate argument if in fact there is not a required additional demand by Vodafone.

  • “The minimum practicable height has been chosen in order to provide the necessary coverage. Headframe antennas will be utilised to ensure a permeable structure, rather thana solid mast, thus softening the impact on visual amenity. All reasonable attempts have been made to minimise the appearance and impact of the installation, including exploring available technologies.” The structure will be a complete eyesore, whether permeable ornot. Given that all reasonable attempts have been made to minimise the appearance and impact, and yet the mast will still tower above all the surrounding buildings, this cannot be deemed to be a suitable location.

  • “The location of the proposal will not impede free and safe flow for highway users.” No comments to make. 

  • “As noted the mast has been sited and designed appropriately so as to avoid, as much aspossible, significant adverse effects on visual and residential amenity. It is located away from being directly in front of residential uses, within the grounds of an existing utility station. The mast will be galvanised.” Galvanising the mast will not detract at all from its enormity. The mast is not located away from residential uses. It is in fact surrounded to the east and southby houses, and to the north by canal boats. The fact that it would be located in an existing utility station is irrelevant since this station is located in a residential area. The site is also next to an historical part of Rickmansworth, and several natural areas (River Colne, the canal, and the Aquadrome.)

  • “The adjoining sites include a waste depot and superstore. The mast is separated from residential uses by trees and the existing pumping station. All efforts have been made in the siting and design of the mast to minimise any impacts on visual amenity to the surrounding uses.” All efforts are insufficient to avoid a huge impact on the neighbouring community. The mast, at 20m tall, will tower above the trees, and the low rise residential surroundings. This is a wholly unsuitable site.

The Supplementary Information Document also states that the “proposal responds positively to the character and appearance of the local environment.” It is impossible to conclude that such an installation could be in keeping with a low rise residential area, and the nearby surroundings of the river, canal, and Aquadrome. The installation would be totally out of place with its surrounding environment. 

OBJECTION TO THE WAY THE PLANNING CONSULTATION PROCESS HAS BEEN CONDUCTED TO DATE: 

  • Insufficient consultation of the local community: The neighbour notification list details only13 addresses, not all of which are residential. The proposed base station will potentially have an impact on a much wider area than these 13 addresses and it is wholly unacceptable that a much larger sample of local residents has not been consulted. Most residents seem to have only been made aware of this proposal due to a letter drop by a concerned member of the community.

In addition, the proposed site is only 450m from St Mary’s C of E Primary School. According to the Supplementary Information document, “no consultation was carried out as the school is considered to be too far a distance from the site to warrant this.” I do not know who has considered the school to be too far away to merit consultation, but I imagine many parents of children at the school would be very interested to have an opportunity to review and comment on this proposal. It is unacceptable that the school has not been consulted on this matter, and I ask the council to inform the school, so that they have the option to respond to the proposal. 

  • Insufficient time to register objections to the proposal: Several documents in the planning application, including fundamental documents such as the design and access statement, and the proposed site plan, were only published on 10th February 2015. This means that practically there have been only two weeks to object to the proposal. One of these weeks was half term when large numbers of residents were away. This is an insufficient amount of time to allow proper consultation with the community.

I urge the council to extend the consultation process, and ask the council to significantly widen the neighbour notification list. This would allow many more of those who will be impacted by this base station to have their fair say on the proposal. 

In conclusion, based on all the reasons noted above, I would like to register strong objections to the planning application.



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